From: Jim Thiele
Sent: November 20, 2007
To: rule-comments@sec.gov
Subject: File No. 4-538


I am writing to express my concerns about the SEC's ongoing review of Rule 12b-1.

I have been a financial advisor for well over 20 years. My practice has always been based upon a "buy and hold" purchase of "A" shares. Many of my clients have been teachers and employees of non profit organizations who contrbute montly to 403-B accounts.

At this time my major focus is service to my existing clients, and I can tell you that as they approach the complexities of retirement, my services are more vital than ever! These services are supported almost exclusively by 12b-1 fees.

If rule 12b-1 were repealed I would be forced to convert all of my clients to a fee basis. Because of the overheaded involved in that process, the asset based fees charged would be at least 4 times as high as clients currently pay via "trails". Many of my small clients would have to go - but where? This cannot be in the best interest of anyone!

It is reasonable to review the investor benefits of 12b-1 fees, but it is obvious to me that the repeal of 12b-1 has the potential to cause great harm to thousands of individual investors who need the support and service of a trained financial advisor. As a result, I urge the SEC to allow Rule 12b-1 to continue to support my efforts to provide needed financial services to middle class American investors pursuing their financial goals.

Sincerely,

Jim Thiele CFP
Financial Network Investment Corporation
4601 Mars
Anchorage AK 99507